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DTSC Schedules Priority Product Work Plan Workshops in August 2014

The California Department of Toxic Substances Control has scheduled two workshops in August at which it will discuss its Priority Product Work Plan and at which the public may provide comments on the Work Plan.  The workshops are scheduled for August 19 at DTSC’s Cypress field office and for August 25 at DTSC’s headquarters in Sacramento.  DTSC has not yet released the Priority Product Work Plan; it expects to do so shortly before the August 19 workshop.

The Priority Product Work Plan will identify the product categories that DTSC will consider in the future for identification as Priority Products under the new Safer Consumer Products Regulations.  Priority Products are chemical-product combinations which, under the new program, must undergo alternatives assessments to ascertain whether “safer” alternatives exist.  Priority Products will be subject to regulatory responses ranging from product use restrictions to product bans, depending on the outcome of the alternatives assessments.  As DTSC explains, the Priority Product Work Plan is intended “to provide signals to the marketplace regarding the scope of product categories that will be under evaluation.”

Earlier this year, DTSC released its draft Initial Priority Products list that identified three Priority Products:  (1) paint and varnish strippers, and surface cleaners, containing methylene chloride; (2) children’s foam-padded sleeping products containing Tris(1,3-dichloro-2-propyl) phosphate; and (3) spray polyurethane foam systems containing unreacted diisocyanates.  DTSC’s identification of this third category of Priority Products has generated considerable controversy, with affected industries criticizing DTSC for failing to consult with stakeholders before identifying that product category, and asserting that the category description is scientifically inaccurate.

Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.